Carlin and Joyce A. Bartschi - Page 9




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          satisfied the verification requirement of section 6330(c)(1),               
          Yacksyzn v. Commissioner, T.C. Memo. 2002-99; cf. Nicklaus v.               
          Commissioner, 117 T.C. 117, 120-121 (2001).  Petitioners have not           
          demonstrated in this proceeding any irregularity in the                     
          assessment procedure that would raise a question about the                  
          validity of the assessment or the information contained in Forms            
          4340.  See Mann v. Commissioner, supra.                                     
               Second, petitioners argue that the Appeals officer made his            
          determination without affording them a hearing.  Respondent                 
          replies that petitioners “were given ample opportunity for a                
          face-to-face hearing.”                                                      
               Because petitioners allege that a hearing under section 6330           
          was not properly held, the question arises whether this Court               
          should remand the case to Appeals to hold the hearing.  Such a              
          question is the subject of Lunsford v. Commissioner, 117 T.C. 183           
          (2001).  There, the Court declined to remand the case to Appeals            
          to hold a hearing at which to consider the taxpayer’s arguments.            
          The Court stated that the Court believed it neither “necessary or           
          productive” to do so because “the only arguments that * * * [the            
          taxpayers] presented to this Court were based on legal                      
          propositions which we have previously rejected.”  Id. at 189.               
               The same is true here.  Apart from their contention about              
          being denied a hearing, petitioners’ only argument in this                  
          proceeding, as gleaned from the allegations of error that they              






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